​FAA Repair Stations FAR Part 145

Posted
on August 31, 2015

Regulations,
regulations, regulations, my gosh, will it ever stop? Enough with the bureaucracy already. But wait, we’re talking about people flying
in airplanes. I’m okay with that. Make all the rules you want. Some of my favorites is limiting a cargo
compartment on a passenger airplane to 25 kilos of dangerous goods, lithium metal batteries prohibited on
passenger airplanes, notifying passengers at check-in, HazMat prohibited, keep
‘em coming!

There are a lot more regulations behind the
scenes. More than the general public is
aware. Of course in our world we have 49
CFR (Code of Federal Regulations). There
are 50 Titles to this Code of Federal Regulations. Title 49 just happens to be the one that
regulates HazMat in transportation – It regulates all modes, Air, Rail,
Highway, and Ocean. With the exception
of the Coast Guard, the actions and policies of the others are carefully and
painfully scrutinized by departments within the government appropriately called
“Administrations.” FMCSA, FRA, and yes, The Federal Aviation
Administration. They write regulations
and how! The FAA’s baby, called, Title
14 has a whole bunch of parts. The
family tree looks something like this.

Part 121 is
for the big boys. Part 135 is for commuters.
Part 29 is for helicopters. They even have
a part for commercial space travel – Part 400.
And deep within the bowels of this monstrosity lays Part 145. Certified Repair Stations. Finally, it's where the rubber meets the road. To become a member of this elite club one
must go through a five phase application process. To help you through the madness the FAA provides a guideline document shown here.

Within the guidance document they
describe the necessary training. Section
301 describes the specific training requirements for a repair station. It includes CFR requirements. And we know all too well 49CFR, Section
172.704.

(a)
Hazmat employee training must include the following:

(1)
General awareness/familiarization training.

(2)
Function-specific training.

(3)
Safety training.

(4)
Security awareness training.

(5)
In-depth security training.

Although all subjects are required, it’s
the Function Specific Training that jumps out at me. I always tell people your function specific
training should mirror your job description.
If it doesn’t, one of them is wrong.
In the FAA Guidance document above, Section 301 b.(3), says, the
training shall include the requirements of the DOT, OSHA, and the EPA. They also add a note, “Do not confuse
employee HAZMAT familiarization and training with the Regulatory requirement of
DOT 49 CFR section 171.8 “hazmat employee/hazmat employer” training standards,
which requires mandatory HAZMAT training for those personnel engaged in the
shipping of hazardous materials.”